Version 1.0 from 15.08.2021
This document does not apply to:
- any personal data processed by xpath.global from its marketplace or ERM (Expatriate Resource Management), which can be found here https://marketplace.xpath.global/privacy-policy;
- any personal data processed by the xpath.global ltd outside the xpath.global platform.
All the definitions from the Terms and Conditions will apply to this document and it will be completed with definitions from GDPR.
xpath.global is the data controller for the recruitement activity. Xpath.global is a limited company registered in Romania, with registration number J40/9812/2007, VAT registration code RO21775247 and the registered office in Bucharest, Romania, Intrarea Solzilor street, No 15, Second floor, district 1.
During the recruitment process, we collect and process information that is necessary for this process that is usually your contact information and all your personal data included in your CV, application form or cover letter. If you are invited to an interview, we will collect and evaluate the data you provide in that case.
The legal basis for our processing of your personal data is your application for the conclusion of an employment contract with us (6(1)(b) GDPR) and, in case you want your CV to be included in our applicant pool, your consent (6(1)(a) GDPR)
We recommend that your application does not contain sensitive personal data, such as personal data disclosing racial or ethnic origin, religion, trade union membership, sexual orientation, health data, etc.
The information we ask for, is used to assess your suitability for employment exclusively. You are not forced to provide any information which you consider it might be a personal data which you feel should not be disclosed.
If you qualify for a job, we might be in the legal position to ask you for more information that is required by the national legislation in order to sign a work contract with you.
The data that we might collect as described above will be used only for the recruitment process to progress your application with a view to offering you an employment contract with us, or to fulfill legal requirements as the next step, if necessary.
On our website, you also have the option of explicitly agreeing that we may process your data beyond the current application procedure. With this consent, we will add your CV in our applicant pool and we may then notify you of new job advertisements or vacancies which should fit your search and interest criteria.
Final recruitment decisions are made by hiring managers and members of our recruitment team. We take into account all the information gathered during the application process. We do not use automated decision making software in the selection process.
Transferring Your Data
In providing the xpath.global Platform, we cooperate with other third party service providers, that are data processors, who offer support in the recruitment process. We have all necessary contracts and agreements in place with these providers to ensure all the legal and privacy protection that is required.
We will not reveal any personal data about our users to third parties without the exceptions mentioned above and having the consent of the applicants.
Exceptionally, we may reveal personal data to competent governmental authorities, upon their legal request according to the applicable laws or when this is necessary to protect the rights and interests of our clients and xpath.global.
We will keep your data for only as long as deemed necessary for the purpose that was intended or and / or as legally required.
Thus we will only store and use your data for as long as it is necessary to decide on the establishment of an employment relationship with you. In principle your application and data will be deleted 6 months after completion of the application process.
As an exception, if you have agreed to the storage of your data in the applicant pool, your applicant data will be deleted 36 months after the end of the application year at the latest or when you withdraw your consent, whichever comes first.
Your rights under GDPR
GDPR provides you with a number of legal rights and some of these rights are listed above in previous paragraphs and below are additional rights explained.
Right of access – You have the right at any time to ask us for a copy of the personal information that we hold about you, and to check that we are lawfully processing it.
Right of rectification – If personal information that we hold about you is not accurate or is out of date and requires amendment or correction you have a right to have the data rectified or completed.
Right of erasure – In certain circumstances, you have the right to request that personal information we hold about you is erased (e.g. if the information is no longer necessary for the purposes for which it was collected or processed).
Right to object to or restrict processing – In certain circumstances, you have the right to object to our processing of your personal information. For example, if we are processing your information on the basis of our legitimate interests, and there are no compelling legitimate grounds for our processing which override your rights and interests.
Right of data portability – In certain instances, you have a right to receive any personal information that we hold about you in a structured, commonly used and machine-readable format.
Right to withdraw consent – In the case where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. You can exercise this right by contacting us at firstname.lastname@example.org.
Exercising your rights
As explained above, you can exercise your right to withdraw consent, and any other rights under GDPR, by informing us by email at email@example.com. Alternatively, you can write to us at the address set out above, or inform us if you prefer to speak to us by telephone or other means.
You also have the right to lodge a complaint with a competent supervisory authority or to complain in a competent court of law.